Jason L. v. Kijakazi

Background

Jason L. applied for Supplemental Security Income on October 20, 2020. He alleged that he became disabled on August 31, 2010, because of major depressive disorder, generalized anxiety disorder, and nicotine dependence.

After a hearing, the Administrative Law Judge (ALJ) found that Jason L. had severe major depressive disorder, anxiety disorder, and nicotine dependence, as well as non-severe obesity. The ALJ found that none of the severe impairments met or medically equaled a listed impairment. The ALJ determined that Jason L. had the residual functional capacity to perform work at all exertional levels, subject to limitations addressing his anxiety and interactions with coworkers, supervisors, and the public. Although the ALJ found that he could not perform his past work as a cashier and sales clerk, the ALJ found that he could perform other jobs existing in significant numbers in the national economy. The ALJ therefore found that he was not disabled. The Appeals Council affirmed that determination.

Arguments and Analysis

Jason L. challenged the ALJ’s treatment of two types of medical opinions. First, he argued that the ALJ did not sufficiently account for the opinion of Dr. Amy Johnson, a state-agency psychologist. Dr. Johnson had opined that Jason L. could interact with coworkers and supervisors on a superficial basis and could have only occasional contact with the public.

The court rejected that argument. It found that the ALJ had considered Dr. Johnson’s opinions and incorporated them into the residual-functional-capacity assessment. The court also found that the ALJ’s limitations were more protective of Jason L. than Dr. Johnson’s opinion and that, in this case, the difference between “superficial” and “occasional” interaction did not change the result.

Second, Jason L. argued that the ALJ failed to adequately address the supportability and consistency of opinions from his treating therapist, Douglas Greenlee. The court concluded that the ALJ’s consideration of Greenlee’s opinions was thorough and thoughtful. The ALJ had noted that some of Greenlee’s stated limitations appeared uncertain because he placed question marks next to some checked limitations. The court explained that the ALJ was not required to analyze every opinion point by point, but was required to carefully review the record. It concluded that the ALJ had done so and had reasonably determined that Greenlee’s opinions were not entirely supported by or consistent with the other evidence.

Ruling

The court reviewed the Commissioner’s decision under the substantial-evidence standard, which asks whether the record contains relevant evidence that a reasonable person could accept as adequate support for the decision. The court concluded that the ALJ’s determination that Jason L. was not disabled was supported by substantial evidence.

Judge Paul A. Magnuson ordered that Jason L.’s Motion for Summary Judgment was DENIED, the Commissioner’s Motion for Summary Judgment was GRANTED, and the matter was DISMISSED with prejudice. The court directed that judgment be entered accordingly.